ROLE AND RESPONSIBILITIES OF AUDITOR IN CLINICAL TRIAL AS PER ICH GCP

Audit
A systematic and independent examination of trial-related activities and documents to
determine whether the evaluated trial-related activities were conducted, and whether the data
were recorded, analyzed and accurately reported according to the protocol, sponsor’s Standard
Operating Procedures (SOPs), Good Clinical Practice (GCP), and the applicable regulatory
requirement(s). (ICH GCP [1])

Qualification of Auditor

The sponsor should specify the qualifications of auditors in auditing procedures and should only
appoint appropriate individual(s) as auditor(s) based on consideration of his/her education/
training, business experience, and ability.

For example:

Knowledge: Necessary laws and regulations, GCP, relevant guidelines, the Declaration of
Helsinki, clinical and pharmaceutical knowledge, SOPs, computerized system validation, etc.

Skills: Communication, writing, language, etc.

Nature: Tenacity, power of observation, analytical capability, decision, sense of ethics, maturity,
etc.

Qualified Auditors

• The sponsor should establish an auditing department with qualified auditors so as to

ensure the proper conduct of audits as part of implementing Quality Assurance.

• Each auditor’s qualification should be documented to verify that he/she is a suitable

person to properly conduct audits, e.g., records of education/training and business
experience.

Roles & responsibilities

• The sponsor should specify the roles and responsibilities of the auditor before starting to
conduct an audit so as to ensure fair and smooth performance of the audit.

• The auditor is responsible for maintaining the confidentiality of information obtained

during an audit, planning (designing and updating) and conducting the audit, and
reporting the audit results.

PREPARED BY: DR.C.SUHAS REDDY 1

ROLE AND RESPONSIBILITIES OF AUDITOR IN CLINICAL TRIAL AS PER ICH GCP

1) PLANNING OF AUDIT

2) CONDUCT OF AN AUDIT

3) REPORT THE RESULTS OF AN AUDIT

4) CORRECTIVE AND PREVENTIVE ACTIONS

5) COMPLETION OF AN AUDIT

6) AUDIT CERTIFICATE

7) KEEPING AUDIT RECORD

1) PLANNING OF AUDIT

Before conducting an audit, the auditor (including the auditing department manager) should
establish a written audit plan (such as an annual plan, a monthly plan, and a plan specific to
each trial or audit) based on the results of the risk assessment according to the written
auditing procedures.

a) Establishing the Goals of Audits

One or more objectives are generally established for a trial audit based on the importance of
the trial with regard to submissions to regulatory authorities, the type and complexity of the
trial, the level of risk to the trial, and any problem(s) identified previous. The most important
part of audit planning is to specify the goal(s) of the audit. By establishing the goal(s) of an
audit, the subject and methods of the audit will be determined and the consistent conduct of
the audit will be ensured.

One or more objectives may be chosen from the following examples:

 Evaluation of the compliance of any organization involved in a clinical trial (pre-

qualification).
 Evaluation of the compliance with regulatory requirements and human subject protection.
 Confirmation of the appropriate conduct of a trial, the credibility of data obtained, and the
condition of record keeping at a participating medical institution(s) through direct access.
 Confirmation of the conduct of monitoring.
 Confirmation of the credibility of a clinical trial/study report.

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ROLE AND RESPONSIBILITIES OF AUDITOR IN CLINICAL TRIAL AS PER ICH GCP

 Early detection and correction and prevention of any existing problems or potential
problems with a system and/or process.
 Early detection and correction and prevention of any existing problems or potential
problems occurring at an institution entrusted with trial-related duties.

b) Designing and Updating the Audit Plan

Planning is essential to systematically, effectively, and efficiently conduct an audit with

consideration of resource management in the auditing department.

Audit plans, such as an annual plan, a monthly plan, and a plan specific to each trial or audit,
should be established based on consideration of the goal(s), contents (e.g.subjects and
methods), and timing of an audit, the progress of the targeted trial, and other relevant factors.

The audit plan should be updated in accordance with progress of the trial or auditing
activity. Prior to conducting an audit, the auditors and the auditee will discuss and adapt the
audit plan, as necessary.

c) Determining the Subject[s], Timing, and Method[s] of an Audit

The subject(s) (e.g., a medical institution, CRO, system, clinical trial/study report,
computerized system validation, and database), timing (e.g., before the start of the trial,
during the trial, after the completion of the trial, or periodically), and the method(s) (e.g.,
sampling, interview, or tour) of an audit should be determined based on the goal(s)
established for the audit.

d) Information in the Audit Plan

An audit plan should provide the following information, although the contents may vary
depending on the type of the plan (e.g., annual plan, monthly plan, or plan for a specific trial
or audit).
 The goal(s) of the audit.
 The subject(s) of the audit.
 The scope of the audit.
 The timing of the audit.
 The name(s), title and address of the auditor (s)(and the auditing department manager).
 The reference documents required.
 The person(s) to whom the audit report will be submitted.
 Timelines for the audit(s) and report(s)（if possible）

PREPARED BY: DR.C.SUHAS REDDY 3

ROLE AND RESPONSIBILITIES OF AUDITOR IN CLINICAL TRIAL AS PER ICH GCP

2) CONDUCT OF AN AUDIT

Auditing is performed by the auditor in accordance with a written audit plan and procedures,
and involves the examination and evaluation of information obtained through investigation of
the audit trail (e.g. essential documents and SOPs) and a trial site(s) (e.g. facilities and
equipment), as well as interviews with the auditee, etc. It is important to specify reference
documents that auditees comply with before performing an audit so as to ensure fair conduct
of audit. The auditor evaluates conformity and compliance with these reference documents.
The auditor should inform the sponsor about the conduct of an audit in advance.

a) Explaining the Auditing Procedures

To efficiently collect accurate information through auditing, the auditor should give the
auditee a prior explanation about the conduct of an audit (e.g. the goal(s) and method(s) of the
audit).

When providing an explanation for the auditee, the auditor should confirm the subject(s) (i.e.
materials and facilities that will be audited), the schedule, and the contact person(s) for the
audit so that both the parties obtain the necessary and full understanding about the audit.

b) Conducting an Audit and Collecting Information

There are two types of sponsor’s audit, i.e., auditing of internal trial-related department(s) and
auditing of external establishment(s) involved in the trial concerned, e.g., a medical institution,
laboratory, and/or CRO. To ensure the smooth conduct of an audit of an external institution,
such as a participating medical institution, laboratory, or CRO, it is important to properly
perform a preliminary internal audit.

When conducting an audit, the auditor should collect audit observations by reviewing the
documents subject to the audit and interviewing the auditee etc. Based on audit observations
collected, the auditor should confirm and document whether or not the audit observations are
compliant to GCP, all applicable regulatory requirement(s), SOPs, the study protocol, and any
other relevant documents and procedures.

Utilization of an audit checklist and a sampling method is useful for the standardization and
efficient conduct of auditing activities.

c) Confirmation and Evaluation of Audit Observations

The auditor should discuss audit observations with the auditee so that the absence of errors

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ROLE AND RESPONSIBILITIES OF AUDITOR IN CLINICAL TRIAL AS PER ICH GCP

can be confirmed. The auditor should then review the confirmed audit observations and
further information can be collected if required.

The auditor should examine (within the auditing department) whether the audit observations
involve any violations of GCP or applicable regulatory requirements, deviations from the
relevant protocol and sponsor’s SOPs, or problems with respect to the reliability of clinical data
and then should determine the observations to be reported as audit findings. The auditor should
also examine weather any of the obtained audit observations could have an influence on other
trails, medical institutions, clinical trial/study systems, etc. When audit findings are reported,
they may be graded according to the level of importance.

3) REPORT THE RESULTS OF AN AUDIT

The auditor should provide written audit results (i.e. an audit report) for the sponsor to make
the auditee recognize audit findings and take the opportunity to make improvements. It will be
useful to provide an opportunity for the auditor to give an explanation about audit results to the
sponsor at the time of submitting the audit report. To preserve the independence of auditing,
the auditor must not be directly involved in the corrective and preventive action (CAPA)
process.

a) Preparation of an Audit Report

The auditor should prepare an audit report based on the results of the evaluation. When an
auditing department manager has been appointed, the audit report should be prepared by the
auditor and if necessary reviewed or approved by the manager.

The contents of an audit report will be as follows:

 Information that identifies the trial, such as the chemical name or identification code of
the investigational drug, the trial title, and the protocol number.
 The person to whom the audit report will be submitted.
 The date of issuing the audit report.
 The subject of the audit.
 The site of the audit.
 The scope of the audit.
 The name(s), title and address of the auditor (s)(and the auditing department manager).
 The name and address of the auditee.
 The date/period of the audit.
 The results of the audit, including audit findings (grading of the findings may be included).
 A list of all persons receiving a copy of the audit report.

The following information may be contained in an audit report depending on the objective(s)

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ROLE AND RESPONSIBILITIES OF AUDITOR IN CLINICAL TRIAL AS PER ICH GCP

of the audit:
 Suggestions for improvement and advice for CAPA.
 Responses to the audit findings.
 The results of the auditor’s confirmation of the auditee’s response.

b) Persons to whom Audit Reports are submitted

The auditor should submit an audit report to the sponsor. The auditor may give a copy of the
audit report to the sponsor’s auditee. In such a case, the auditor should pay special attention to
ensuring the confidentiality of the contents of the report and should handle the report with due
caution. Concerning audit reports, ICH GCP 5.19.3 (d) states the following:

‘To preserve the independence and value of the audit function, the regulatory authority(ies)
should not routinely request the audit reports. Regulatory authority(ies) may seek access to an
audit report on a case-by-case basis when evidence of serious GCP non-compliance exists, or
in the course of legal proceedings.’

4) CORRECTIVE AND PREVENTIVE ACTIONS

Implementation of a CAPA plan after the conduct of an audit is necessary to eliminate present
and potential causes of non-conformity and prevent re-occurrence or future occurrence. Once
the conduct of the audit is complete the auditor should be provided a CAPA plan to the auditee
that will be utilized to remediate issues of non-compliance and potential non- compliance
identified during the audit process. The CAPA plan should, at minimum, require the auditee to
identify the root-cause of audit findings and describe whether corrective and/or preventive
actions will be necessary to address the audit findings.

5 COMPLETION OF AN AUDIT

Upon receipt of the preliminary responses to the CAPA from the auditee, the audit is
completed. Follow-up should be performed depending on the significance of the audit
findings. CAPA follow-up and subsequent effectiveness verification should be ensured by
continued interaction between the auditor and auditee until mutual agreement has been met
that the CAPA have been addressed.

PREPARED BY: DR.C.SUHAS REDDY 6

ROLE AND RESPONSIBILITIES OF AUDITOR IN CLINICAL TRIAL AS PER ICH GCP

6 AUDIT CERTIFICATE

The auditor (including the auditing department manager) should prepare an audit certificate at
the request of the sponsor. The sponsor should attach the audit certificate to a clinical
trial/study report of the targeted trial.

The audit certificate should contain the following information:

 Information that identifies the trial, such as the chemical name or identification code of
the investigational drug, the trial title, and the protocol number.
 The date of issuing the audit certificate.
 The contents of the audit (e.g., subjects and date of the audit, and date of issuing the audit
report).
 The name(s), title and address of the auditor (s)(and the auditing department manager).
 The name and workplace address of the auditee.

7 KEEPING AUDIT RECORDS

Audit records should be kept according to sponsor’s SOPs for record keeping. The SOPs
should specify the procedures for keeping or destroying audit-related records, as well as the
place, subject, and duration of record keeping.

References

[1] ICH GCP. ICH Harmonized Tripartite Guideline, Guideline for Good Clinical Practice,
Recommended for Adoption at Step 4 of ICH process, 1 May 1996
[2] ISO 19011. Guidelines for quality and/or environmental management systems auditing,
first edition 1 October 2002
[3] ISO 9000. Quality management systems – Fundamentals and vocabulary, second edition,
15 December 2000

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